DOES SITE HAVE ANY PERMISSION AT ALL?
CLEVER IDEA: LET'S CALL IT: "CEMENT KILN BYPASS DUST!"
REGULATORY COMMITTEE : QUESTIONS
Ability of Environment Agency and planners queried on 20 January, as there is much confusion about:
* Which actual site they are permitting - co-ordinates?
* What is hazardous waste bypass dust?
* Why it has no PPC operating permit?
* What, if any, Waste Management License exists?
* Why Stratford on Avon has inadequate Agency copy files?
* Why the planning inspectorate says the " PPC appeal is in abeyance from 2004 refusal, and 2006 appeal?"
TEMPORARY EXTENSION (NOT CHANGE OF USE!!) 4 March 2008 - "No waste other than Cement Kiln Dust, spillage materials, road sweepings, laboratory test samples. and kiln bricks arising from the Rugby Cement works Lawford Road shall be imported to the site" TO 31/12/08.
Various grids 420.633 and 418.631.
QUESTIONS QUESTIONS?
HAZARDOUS WASTE to be labelled on the HGVs, and also an emergency telephone number, or not? Officers report 4.6 claims "an interchangeability of the terms CKD and BPD." ERR NO! Another question "this is not a one-off UK's only cement plant so how do others transport and dump the BPD?" Answer: Cement HAZARDOUS WASTE LANDFILLS are usually on site "in house" in RURAL areas where the raw material is NORMALLY dug out, not in town centres as in Rugby! Rugby Parkfield Road landfill was refused IPPC Permit, and application withdrawn in 2006.
It is a closed landfill as too dangerous near residents - cumulative impact! Does hazardous dust escape from lorries in the town and along the route?
Cemex say "NO!" RBC EHO express concern, and request monitoring to protect residents.
AGENCY PERMITS OBSCURED - BY DUST?
BUO244IE: BVI666IX: NIM641 granted 14/07/08 for one year only; AJO106 granted 21/07/08 for one year only?? No EU Waste Codes; description of the BPD; analysis of the dust; and also no explanation of the difference between CKD and BPD. Is it an "irritant and corrosive" see H4 and H8 substances which through immediate, prolonged, or repeated contact with the skin or mucous membranes can cause inflammation, burns and worse.
CEMEX:
As you are aware we have been dumping bypass dust for 8 years - you gave a permission in March 2008 for a new cell 4. This cell 3 is a fully engineered landfill (for CKD??) and subject to monitoring by the EA. We thought it was OK just to carry on. There is a degree of confusion and lack of info between the difference between the CKD and BPD - there is uncertainty - they are similar, only different because taken out of different parts of the plant. BBD is only classified as hazardous because it is high in calcium oxide and is an irritant. We re-cycle it back into the process. (in cement mills) We re-use as much of it as we can and only dump what we have to. It is nodulised so as not to be spread by the wind, and sheeted clay lorries bring it here. You have given a planning permission for hazardous BPD in cell 4 and that is not built yet. We want to fill this cell with 30,000t more and landscape it. We have given comprehensive ES on this with so much detail.
COUNCILLOR:
I am under the impression that since 2000 that it had a previous permission for CKD so what has been happening here - over a lengthy period of years - an unauthorised operation has been taking place.
WCC OFFICER:
We had given a planning permission for CKD but there were no planning conditions attached to it to say only CKD - if I remember - and then BPD got re-classified as hazardous waste. We overlooked the EIA and gave a series of temporary permissions for CKD. It seem they are valid unless the High Court strikes them down. It is a very grey area. Planning permission may well have been granted (for non-hazardous waste) but we failed to realise an EIA was necessary - as a result of BPD being dumped instead of CKD, and the BPD being given a "new classification" as hazardous waste.
CEMEX:
A Hazardous Waste Management License is monitoring it regularly and it is subject to regulations. It is an irritant - I am not a medical expert but it is classed as an irritant. We use returning clay lorries. To prevent it from becoming airborne we nodulise it and sheet it. No records of it ever coming out of lorries. Bypass Dust did escape from the cement plant on November 16/17 and it fell on people but the EA are taking no further action (Obviously CAN NOT as emitted on a "shut down" with no Emission Limits in place!! Rugby residents are furious - but they can get their cars cleaned free - with receipt!)
COUNCILLOR/S:
I am sure she said dust sometimes came from the lorries?
Hazardous waste is transported on many lorries and tankers on the motorways you see them with signs - but you say it is categorised recently as hazardous waste - what level of hazard is it? Dust and powder are bad for asthmatics - so are garden products - dust causes asthma.. there must be a hierarchy's of hazards about it? Where does it come in table of hazards - mid way? We need technical knowledge about it and we should defer for more information. But we have permission for cell 4 last year and we have been badly let down by the EA or WCC or both! A deliberate cloud has been placed over it to get these grants of PP. For 8 years stuff has been put in the ground and we did not know it - transported at risk to people - exposed for 8 years with no planning permission. We have a Duty of Care to stop it going on any more.
WCC
But the EA have been monitoring it and they are in a transition stage between Waste Management License and PPC permit. BUT said a councillor the EA NEVER came back and told us what we asked - NEVER - and we have asked. WCC officer: I cannot remember what we approved CKD or BPD.
THE JURY'S OUT!!
They DEFERRED voting six for, and five against. For more information: history of site; EA response; what is nature of dust, and health impact; can they just make it a Change of Use from non-hazardous to hazardous, and overlook the 8 years 140,000 tonnes and allow another 30,000 tonnes until the new cell 4 is ready? Next exciting instalment WCC Regulatory Committee 17 February. (see WCC web for committee papers and long history of the site.)
Photograph entitled 'Whisper' by Brian Scott
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